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Retirement income framework development: KPMG's submission to Treasury

Retirement income framework: KPMG's submission

On 15 June 2018, KPMG lodged a submission to the Federal Treasury in response to the Retirement Income Covenant Position Paper – Stage One of the Retirement Income Framework (May 2018). In our submission, KPMG expressed support for the establishment of a Retirement Incomes Framework which aligns to the objective of superannuation, while recommending further consideration of product design and advice models.

Linda Elkins

National Sector Leader, Asset & Wealth Management

KPMG Australia


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On 19 February 2018 the Minister for Revenue and Financial Services announced the establishment of a consumer and industry advisory group to assist in the development of a framework for Comprehensive Income Products for Retirement (CIPRs).

In the 2018-19 Federal Budget More Choices for a Longer Life Package the Federal Government committed to introducing a retirement income covenant as the first stage of the Government’s proposed retirement income framework.

On 17 May 2018 the Federal Treasury released a Retirement Income Covenant Position Paper which detailed a series of Covenant Principles and Supporting Principles for consultation.

KPMG's submission

KPMG’s observations and recommendations submission is supportive of measures proposed in the Position Paper that result in:

  • more education to members to enable them to make informed decisions
  • flexibility in the advice model
  • flexibility of product design.


Our submission discusses observations and concerns regarding matters including:

  • consumer protection versus trustee safe haven
  • two tier advice model
  • cross-subsidisation of advice (retirement advice via intra fund).

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